Justia Ohio Supreme Court Opinion Summaries

Julie Steinle filed a complaint for divorce against Garrette Steinle, and the case was assigned to Judge John Dewey. Garrette filed three motions for partial summary judgment dealing with various assets at issue in the divorce. After Judge Dewey granted the motions in part Garrette filed a motion for findings of fact, requesting that Judge Dewey either find that all of the facts he had asserted in the motions were uncontroverted or provide a list of those facts that the judge found to be in dispute. Judge Dewey denied Garrette’s motion. Garrette then filed this action in mandamus requesting an order directing the judge to issue findings of fact. The court of appeals granted Judge Dewey’s motion to dismiss. The Supreme Court affirmed, holding that the court of appeals properly dismissed the complaint and that Garrette had not shown a clear legal right to the requested relief. View "State ex rel. Steinle v. Dewey" on Justia Law

Dennis Carter sustained serious injuries when Larry Reese attempted to move a tractor-trailer that had pinned Carter’s leg between the trailer and a loading dock. Carter and his wife sued Reese. Reese asserted Ohio’s Good Samaritan statute as a defense. The trial court granted summary judgment in favor of Reese pursuant to the statute. The court of appeals affirmed. The Supreme Court affirmed, holding that Reese was not liable in civil damages pursuant to Ohio’s Good Samaritan statute because (1) Reese administered emergency care at the scene of an emergency, and the statute expressly states that no person shall be liable in civil damages for acts performed at the scene of an emergency, and (2) no allegation of willful or wanton misconduct was asserted against Defendant. View "Carter v. Reese" on Justia Law

In 2014, Defendant was convicted of first-degree-felony rape and kidnapping for offenses he committed in 1993. The trial court sentenced Defendant in accordance with the sentencing law in effect at the time of the 1993 offenses. Defendant appealed his sentence, arguing that he should have been sentenced under the law in effect at the time of his 2014 sentencing. The law in effect in 2014 reduced the potential prison sentences for Defendant’s offenses as compared with the potential prison sentences for those offenses under the law in effect in 1993. The Court of Appeals agreed with Defendant, vacated his sentence, and remanded for resentencing. The Supreme Court affirmed, holding that Defendant was entitled to the benefit of the shorter potential sentences under the law in effect at the time of sentencing. Remanded. View "State v. Thomas" on Justia Law

Dayton Public Schools notified Cox of its intent to terminate her employment for allegedly striking a student. An arbitration award, finding just cause for her termination, was handed down on December 10, 2013. The arbitrator e-mailed the decision to the School District attorneys on December 10, but Cox was not included as a recipient of the e-mail. On December 18, 2013, the Board of Education passed a formal resolution adopting the arbitrator’s decision and directed that Cox be served with the order by certified mail. On March 10, 2014, Cox moved to vacate, modify, or correct the arbitration award. The School District argued that notice of a petition seeking the vacation or modification of an arbitration award pursuant to R.C. Chapter 2711 must be received by the adverse party or its attorney within the statutory three-month period contained in R.C. 2711.13. The trial court dismissed. The Court of Appeals reversed; the Supreme Court of Ohio affirmed. The three-month period for service of Cox’s motion began on December 11, 2013. On the same numerical day three months later, Cox sent notice of her motion by certified mail. Service was complete at the time of mailing and was timely. View "Cox v. Dayton Pub. Schs. Bd. of Educ." on Justia Law

Hand entered no-contest pleas in Montgomery County to first-degree felonies (aggravated burglary, aggravated robbery, and kidnapping) and two second-degree counts of felonious assault. Each count had a three-year firearm specification attached, to which Hand also entered no-contest pleas. During the plea hearing, the parties agreed to a total six-year prison term with three of the years being mandatory because they are related to the merged firearm specifications, R.C. 2929.14 and 2941.145. The parties disputed whether the three years for the other offenses was also a mandatory term, based on whether Hand’s prior juvenile adjudication for aggravated robbery under R.C. 2911.01(A)(3) should operate as a first-degree felony conviction to enhance his sentence. The court ruled that Hand’s prior juvenile adjudication required imposition of mandatory prison terms under R.C. 2929.13(F). The appeals court affirmed. The Supreme Court of Ohio reversed. Treating a juvenile adjudication as an adult conviction to enhance a sentence for a later crime is inconsistent with Ohio’s system for juveniles, which is predicated on the fact that children are not as culpable for their acts as adults and should be rehabilitated rather than punished. In addition, juveniles are not afforded the right to a jury trial. View "State v. Hand" on Justia Law

After a jury trial, Appellant was convicted of aggravated murder with two death-penalty specifications. The trial court sentenced Appellant to death. On appeal, the court of appeals vacated the death sentence, concluding that the trial judge’s use of the assistant prosecutor to assist in preparation of the sentencing opinion was improper. On remand, the trial court again sentenced Appellant to death. The Supreme Court affirmed the convictions and sentences, holding (1) in regards to the trial court’s resentencing of Appellant, the court in the sentencing opinion improperly failed to consider Appellant’s allocution, but the error was harmless; and (2) there was no other prejudicial error. View "State v. Jackson" on Justia Law

Defendant was entered a guilty plea to charges of murder, domestic violence, and aggravated murder with capital specifications for the murders of his former girlfriend, their two-year-old son, and his girlfriend’s nine-year-old daughter. A three-judge panel unanimously sentenced Defendant to death of the aggravated murders of the two children and to fifteen years to life for his girlfriend’s murder. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) the panel did not err by failing sua sponte to order Defendant to undergo a competency evaluation; (2) the evidence presented during the plea hearing was sufficient to convict Defendant of the escaping detection specification attached to an aggravated murder, and defendant’s conviction of that specification was not against the manifest weight of the evidence; (3) defense counsel provided constitutionally effective assistance during the plea and mitigation hearings; (4) Defendant was not denied due process of law and a fair trial when the panel admitted and considered graphic photographs during the plea and mitigation hearings; and (5) Defendant’s death sentence was appropriate and proportionate. View "State v. Montgomery" on Justia Law

In 2013, Shawn Valentine was elected trustee of Spencer Township in Lucas County. In 2015, Valentine, who serves in the Ohio Army National Guard, told the two other trustees of his military deployment but that he did not intend to resign his position as trustee. The two trustees subsequently voted to declare Valentine’s office vacant and then appointed one of the trustees, D. Hilarion Smith, to take Valentine’s trustee position. Relator, the Lucas County prosecuting attorney, sought a peremptory writ of quo warranto seeking to remove Smith from the office of township trustee and a declaration that Valentine was the rightful holder of that position. The Supreme Court granted the writ, holding (1) under the plain language of Ohio Rev. Code 503.241, Smith usurped the title and authority of Valentine’s office of township trustee; and (2) the board of township trustees violated the Open Meetings Act when it unlawfully appointed Smith to Valentine’s trustee position. View "State ex rel. Bates v. Smith" on Justia Law

On December 22, 2015, Respondents submitted part-petitions in support of an initiative to enact the "Ohio Drug Price Relief Act." On February 29, 2016, the Ohio Manufacturers’ Association and others commenced this original protest action identifying three alleged defects in the part-petitions that they claimed should cause the part-petitions to be discounted in their entirety. The Supreme Court sustained the challenge in part, holding that 10,303 signatures, including the signatures on all part-petitions circulated by two petition circulators in particular, were erroneously validated because either the circulators submitted false information in their circulator statements or the part-petitions had overcounts. View "Ohio Manufacturers' Ass’n v. Ohioans for Drug Price Relief Act" on Justia Law

Defendant, a police officer, was charged with one count of unlawful sexual conduct with a minor and one count of sexual battery. A bench trial resulted in Defendant’s conviction for sexual battery under Ohio Rev. Code 2907.03(A)(13), which makes peace officers strictly liable for sexual conduct with anyone under the age of eighteen when the offender is more than two years older. The appellate court reversed, concluding that section 2907.03(A)(13) violated equal protection and was facially unconstitutional. The Supreme Court affirmed, holding that the statute is an arbitrarily disparate treatment of peace officers that violates equal protection principles under the state and federal constitutions. View "State v. Mole" on Justia Law